NEWARK, N.J. - The U.S. Supreme Court's ruling in Federal Trade Commission v. Actavis does not apply to a settlement between a holder of a drug patent and a generic manufacturer that delays entry of a generic drug but does not involve a cash payment, a federal judge in New Jersey ruled Jan. 24 (In re: Lamictal Direct Purchaser Antitrust Litigation $(All Direct Purchaser Actions$), No. 12-995, D. N.J.; 2014 U.S. Dist. LEXIS 9257).